Delegate Support Services Pty Ltd (DelegateSS) respects your right to privacy and we understand that you want to know about how we manage the confidentiality and security of the information you might provide in the course of your dealings with us. We take your privacy very seriously and are committed to safeguarding the privacy of our all of our members, partners, app users and website visitors that will give you the most powerful and safe online experience.

An important part of our commitment to proactively ensuring your privacy, is our strict adherence to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information. Detailed information is also available at the Office of the Australian Information Commissioner website.

The information contained in this policy applies to the Brevity app and website and governs collection, storage, use and disclosure of personal information. By providing personal information to us and using the Brevity app and our website, you consent to the collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

How we collect your personal information. Personal information is information we hold that is identifiable as being about you.

We collect personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access the Brevity app or website and when we provide our services to you.

In order to access the Brevity app and establish an Account, users will be provided the following:

• Username
• Generic Password – you will be able to change the password upon first login to the app
• Company Code to access your NDIS Allocated budgets

Use of your personal information.

We may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.

Except as specifically set out in this Privacy Policy, we will not sell or disclose your personal information to any other person or use your personal information for any other purpose without your prior consent, unless authorised or required by law. Generally, we will only use and disclose your personal information for the following purposes:

• To provide you with information you request about us or the products or services we offer through DelegateSS
• To provide information to persons expressly authorised by you
• To manage the DelegateSS service (including your Account)
• To provide products or services you request from time to time
• To determine and notify you of what products or services (including third party products and services) we consider are likely to be of most interest to you
• To process and obtain payment for any products or services you order from us through DelegateSS
• To understand how you use the DelegateSS service and to help us improve the DelegateSS service, our marketing and the way we do business
• If necessary, to verify your identity, and
• To contact you for direct marketing and promotional purposes including providing you with information about new products or services, events and special offers, unless you tell us that you do not wish to receive this type of information.

We may use your data and any personal information which you have provided us to enhance the service we are providing you. DelegateSS may use anonymous and aggregated data from our customers and disclose this in a non-personally identifiable manner to third parties, including:

• Advertisers and other third parties for their marketing and promotional purposes such as how many users clicked on their advertisement
• Users of DelegateSS services in order to provide them benchmarks for comparing themselves against the broader DelegateSS community

We may contact you by a variety of measures including, but not limited to telephone, email, video calls, SMS or mail.

DelegateSS takes all reasonable steps to allow you control over your data. You may cancel your Account by emailing us at any time at envision@delegatess.com.au. Your Account will be deactivated immediately and we will disconnect any connection with your Account information we have established. DelegateSS reserves the right to use any aggregated and anonymous data derived from your utilisation of the service to this point. This data cannot identify you in any way.

Disclosure of your personal information.

We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of www.delegatess.com.au its customers or third parties.

DelegateSS may disclose your personal information to third parties in order to allow them to provide the good and/or services you have requested and to government agencies who provide funding for those goods and/or services.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

You can access your personal information held by DelegateSS

DelegateSS seeks to ensure that the information it holds about you is accurate, up to date, complete and relevant. If you learn that personal information that DelegateSS holds about you is inaccurate, not to date, incomplete, irrelevant or misleading you should contact DelegateSS so we can promptly correct it.

If you wish to see what information DelegateSS holds about you, you can check your Account on the Brevity app. This will contain almost all of the information that DelegateSS maintains about you. If you think that we may have additional personal information, you can ask to access that information, please email us at envision@delegatess.com.au.

Sometimes we may not be able to provide you with access to all of your personal information and if this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

Complaints about privacy.

If you have any complaints about our privacy practices, please send us details of your complaint addressed to the Operating Manager, Delegate Support Services Pty Ltd, PO Box 246, BOOVAL FAIR QLD 4305 or via envision@delegatess.com.au. We will investigate the complaint and provide you with a written response (which could include email) as soon as we can and normally within 30 days from the date you first contacted us.

Changes to our Privacy Policy.

Please be aware that we may change this Privacy Policy in the future. We may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website. Please check back from time to time to review our Privacy Policy.

Direct communications from DelegateSS

When you register to use the DelegateSS services you provide your consent to DelegateSS for DelegateSS to send direct communications to you, including notifications and direct marketing communications. You may opt out of marketing communications if that is your wish. You can opt in or out of receiving direct marketing communications from DelegateSS by sending a request to envision@delegatess.com.au. There are however, certain forms of essential correspondence users cannot opt out of receiving, which include correspondence relating to confirmation of your registration with the Brevity app, notifications of changes to this Privacy Policy or anything else we are required or authorised to send you in accordance with Australian law.

Cookies

We use “cookies” in order to provide you with the best online experience possible and to identify you on return visits. Cookies are very small files which are sent and stored in your web browser on your device’s hard drive. DelegateSS

may access these to understand more about your preferences in order to deliver a more relevant experience. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings.

Our website may from time to time use cookies to analyses website traffic. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

Third party sites.

The Brevity app may contain links to other websites operated by third parties. DelegateSS do not recommend or endorse those other websites or the products and services provided on those sites. DelegateSS is not responsible for the condition or content of those websites as DelegateSS do not have control over those websites. DelegateSS make no representations about the accuracy of any information contained on any other websites and is not responsible for any loss arising directly or indirectly from you using, assessing or attempting to access those websites.

Advertising.

Some of DelegateSS services may display advertisements and promotions and you hereby agree that DelegateSS may place such advertising and promotions on the DelegateSS website or on, about or in conjunction with your content. The manner, mode and extent of such advertising and promotions are subject to change without specific notice.

Our commitment to a better digital experience.

DelegateSS are committed to providing you with a better online experience and more personalised services and endeavour to do so as technology evolves and new products become available.

It will be necessary for our Privacy Policy to change from time to time to account for further developments of the DelegateSS service offering and we will provide you with reasonable notice of any significant changes.